Jurisdiction for Section 143(3) Income Tax Assessments Hinges on Territory, Residence, Not PAN Jurisdiction. Revenue Argument Rejected.

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....Jurisdiction to frame the scrutiny assessment u/s 143(3) - Jurisdiction recognized by the Act are based on territory, residence, pecuniary, classes of assessee like companies, firms etc. Since the PAN jurisdiction must be an internal arrangement of the Department which does not have the sanction of law and since it is not recognized by the Statute, therefore this contention of the revenue cannot be accepted and so it is rejected. - AT....